The Financial Action Task Force (FATF) updated the list of high-risk countries (i.e., high-risk third countries, known as HRTCs) in June 2025. In response to that, both HM Treasury in the UK and the European Commission for the EU both updated their lists.The U.S. uses the FATF list for high-risk third countries, with a sanctions program specific to countries.
What’s changed?
Notably, the British Virgin Islands have been added as a high-risk jurisdiction (grey list) on both the FATF and UK lists. As a reminder, in another recent update, the UK went a step farther than others (namely FATF and the EU), by adding seven jurisdictions to the black list (in addition to Iran, Myanmar and North Korea): Congo, Haiti, Mali, South Sudan, Syria, Venezuela and Yemen.
Why is knowing what locations are flagged as high-risk important?
Read more about these latest updates
- FATF – Call to Action (“black list”): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-june-2025.html
- FATF – Increased Monitoring (“grey list”): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html
- UK update: https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries–2/money-laundering-advisory-notice-high-risk-third-countries–2
- EU: https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en
- U.S.: https://ofac.treasury.gov/sanctions-programs-and-country-information
What does this mean for your art business?
The ArtAML™ platform automatically checks for high risk jurisdictions, and countries that border high-risk jurisdictions, in association with:
- Residential address (for private individuals and the UBOs of companies)
- Registered address (for companies)
- Source of funds (for all types of customer)
- Reliance partner (the Art Market Participant or regulated business upon whose AML checks you’re relying)
- If a high-risk (or bordering) jurisdiction is identified in our platform, a red flag is raised, which triggers conducting Enhanced Due Diligence. You will need to take a risk-based approach based on information related to the transaction, in context of the risks your own business faces of being a target of ML/TF activities.
Not yet using ArtAML™ for compliance checks?
Or need to do a manual high-risk jurisdiction check? Review the current lists of high risk jurisdictions via the following links: